Interactive bloodborne pathogen training by telephone

April 16, 1992

Ms. Maureen M. Gritz
Director Quality Assurance
Martin Memorial Hospital
[Recipient address omitted]

Dear Ms. Gritz:

This is in response to your letter of February 24, addressed to Dan Mick, Office of the Solicitor. You requested clarification concerning a training requirement in 29 CFR 1910.1030, "Occupational Exposure to Bloodborne Pathogens".

Section (g)(2)(vii)(N) of the standard states that there must be "an opportunity for interactive questions and answers with the person conducting the training session". The Occupational Safety and Health Administration (OSHA) [CPL 2-2.69, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens"] has interpreted that language to mean that if a generic program is used (even an interactive computer program), it must be supplemented with the site-specific information required by the standard and a person must be accessible for interaction with trainees.

Whether or not the use of telephone access for the question and answer period would meet OSHA requirements would depend on such factors (assuming competency of the trainer) as accessibility and the ratio of trainers answering the phone to number of employees calling with questions. The requirement may be satisfactorily fulfilled without the trainer being physically present in the room with the employee.

Because many of these requirements are performance based, compliance officers will determine, on a case-by-case basis, whether the training that has been provided is effective and adequate. This is accomplished through observation of work practices and employee interviews to determine that the training (including written material, oral presentations, film, videos, computer programs, and audiotapes) is presented in a manner that is appropriate to the employees' education, literacy level, and language.

We hope this information is responsive to your concerns. Thank you for your interest in worker safety and health.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

[Corrected 10/29/02]